Mr. Gerardo RiosEnvironmental Protection Agency Region IX

75 Hawthorne Street

San Francisco, CA 94105

Subject: Rio Bravo Poso: Minor Modjflcation to

(PSD Permit No. NSR 4-4-8; SJ 85-06)

Dear Mr. Rios:

Rio Bravo Poso (Poso) seeks permission to combust biomass, in addition to the permitted fuels

(coal, petroleum coke, and tire-derived fuel). The biomass will be received and fed into the

boiler using existing equipment currently employed to feed fuel; no new equipment or

physical modification to jy existing equipment is being proposed. Hence no anticipated

increase in emissions, including fugitive emissions, will result from this permit modification.

Rio Bravo Poso:

• Proposes to add biomass to the three currently allowed fuels (petroleum coke and/or

coal and up to 20% by weight oftire derived fuel). In addition, the fuel throughput limit

is being modified to bring it into alignment with the Title V permit wording. The

following changes to Permit Condition IX.H. are requested:

Original Wording:

Poso shall not consume more than 34,855 pounds (on a dry basis) per hour ofsolid fuel inthe proposed cogeneration unit. The fuel shall be comprised of a blend of petroleum coke

and/or coal and up to 20% by weight oftire derived fuel and shall have a maximum

sulfur content of 4.0 percent by weight as measured by current ASTM methods.

Change to:

Poso shall not consume more than 836,520 pounds (on a dry basis) per day on a 30-dayrolling average ofsolid fuel in the proposed cogeneration unit. The fuel shall be

comprised of a blend of petroleum coke and/or coal and up to 20% by weight oftire

derived fuel and shall have a maximum sulfur content of 4.0 percent by weight as

measured by current ASTM methods. In addition, two (2) pounds of biomass fuel of no

more than 4.0% by weight sulfur may be substituted for one (1) pound of coal or coke

fuel.
836,520 pounds per day (calculated by multiplying 34,855 pounds per hour times 24

hours per day).

The reason for the request to put the 30-day rolling average into the permit is: in the 1995 revision to the PSD it appears that the original averaging period of “on a monthly basis”

was inadvertently left out. We understand that the concept of using block averages has generally been replaced with using rolling averages and we believe that a 30-day rollingaverage captures the intent ofthe original monthly average (block average) requirement and meets EPA’s recent guidance.

The request to substitute two (2) pounds of biomass fuel for one (1) pound of coal or coke reflects the relative difference in higher heating values ofthe fuels.

• Will continue to employ Best Available Control Technology (see recent assessment

performed by the San Joaquin Valley Air Pollution Control District (SJVAPCD)) (refer

to attached table).

• Will conduct a six-month “trial bum” to confirm that the emission limits can be met

with biomass fuel. Poso agrees to share all information with EPA. Poso’s desire is to

commence this trial bum in the third quarter of 2010.

BACT for NOx is Selective Non-Catalytic Reduction (ammonia injection currently used). BACT for S02 is sorbent injection (limestone injection currently used). BACT for CO is the

circulating fluidized bed combustion process (currently used).

The current permitted emission limits and the actual emissions from the annual emission

inventory are presented below.

Actual Emissions

YEAR 2005 2006 Average Limit

NO (tons/year) 142.38 140.82 141.60 170.38

SO2(tons/year) 50.96 50.43 50.70 61.32

CO (tons/year) 74.77 85.08 79.93 460.34

PM10 (tons/year) 9.02 8.51 8.76 18.88

Note that the S02, annual emission average is within 40 tons per year of current limit. The NOx

annual emission average is within 25 tons per year of current limit. The VOC annual emission

average is within 25 tons per year of current limit. Likewise the PM1O annual emission average
uent NO (lbs/br) SO2(lbs/br) CO (lbs/br)

Limit 38.9 14.0 105.1

The emissions from the facility are not expected to change on an hourly basis.

It is Poso’s understanding that by being below the significant emissions increase thresholds for a

major modification, this request can be processed as a minor modification.

Please refer any questions you have regarding this request during your review to Dr. Ted Guth at

(619) 987-1111. Poso thanks you in advance for the expeditious review ofthis request, as well

as your continued support and guidance.

Sincerely, -

n

Bill Rossiter

Vice President

Title V Responsible Official

cc: Maggie Estrada, Constellation Energy

Ted Guth, Rio Bravo

Facility files
)

Pollutant Achieved In Pracilue or Technologically conialnad In the SiP Alternate Susie Feasible Egu!pment Co

- 183 ppmvd, nalura! gee aukWary fuel

NOx 0.10 IhIMMBtu, ammonia Injection and natural gas lluldIiedOfrcuiatlng bed combustor wVNH3 aLl)dllary fuel lnjaollon PMIO 0.O45lbIMM8tu, baghouse or ESP, and natural gas auNflialy fuel

SOx 23 ppmvd Imestone Injeotlon and natural gas audllaiyfueI

VOC 0,02 IWMMBIu, nelural gas auxilialy fuel

• BACT Ia the most stringent control technique for the emissionS unit and class a! source. Contra! techniques that are not achieved In practice or contained In a’a state ImplementsVon plan must be cost eIThclIve as well se feasible. Economlo analysis to demonstrate coat offecllvenosa is requited (or sit datermlneUons Thla is a Summary Page that are not achieved In practice orconWned In en EPA approved State lmplemenlallozr Plan. for thie Class of Souroe Permit SpeolrIo SACT Determinations on Next Page(s)
y 

d, Ca 93308

Mr. Gerardo Rios

Environmental Protection Agency Region IX

75 Hawthorne Street

San Francisco, CA 94105

Subject: Rio Bravo Jasmin: Minor Modjfication to

(PSD Permit No. NSR 4-4-8; SJ 85-07)

Dear Mr. Rios:

Rio Bravo Jasmin (Jasmin) seeks permission to combust biomass, in addition to the permitted fuels (coal, petroleum coke, and tire-derived fuel). The biomass will be received and fed into theboiler using existing equipment currently employed to feed fuel; no new equipment or physical modification to yexisting equipment is being proposed. Hence no anticipated increase in emissions, including fugitive emissions, will result from this permit modification.

Rio Bravo Jasmin:

• Proposes to add biomass to the three currently allowed fuels (petroleum coke andlor

coal and up to 20% by weight oftire derived fuel). In addition, the fuel throughput limit

is being modified to bring it into alignment with the Title V permit wording. The

following changes to Permit Condition IX.H. are requested:

Original Wording:

Jasmin shall not consume more than 34,855 pounds (on a dry basis) per hour ofsolid fuel

in the proposed cogeneration unit. The fuel shall be comprised of a blend of petroleum coke and/or coal and up to 20% by weight of tire derived fuel and shall have a maximumsulfur content of 4.0 percent by weight as measured by current ASTM methods.

Change to:

Jasmin shall not consume more than 836,520 pounds (on a dry basis) per day on a 30-day rolling average ofsolid fuel in the proposed cogeneration unit. The fuel shall becomprised of a blend of petroleum coke and/or coal and up to 20% by weight oftire derived fuel and shall have a maximum sulfur content of 4.0 percent by weight as

measured by current ASTM methods. In addition, two (2) pounds of biomass fuel of no

more than 4.0% by weight sulfur maybe substituted for one (1) pound of coal or coke fuel.
836,520 pounds per day (calculated by multiplying 34,855 pounds per hour times 24

hours per day).

The reason for the request to put the 30-day rolling average into the permit is: in the 1995

revision to the PSD it appears that the original averaging period of “on a monthly basis”

was inadvertently left out. We understand that the concept of using block averages has

generally been replaced with using rolling averages and we believe that a 30-day rolling

average captures the intent ofthe original monthly average (block average) requirement

and meets EPA’s recent guidance.

The request to substitute two (2) pounds of biomass fuel for one (1) pound of coal or

coke reflects the relative difference in higher heating values ofthe fuels.

• Will continue to employ Best Available Control Technology (see recent assessment

performed by the San Joaquin Valley Air Pollution Control District (SJVAPCD)) (refer

to attached table).

• Will conduct a six-month “trial burn” to confirm that the emission limits can be met

with biomass fuel. Jasmin agrees to share all information with EPA. Jasmin’s desire is

to commence this trial burn in the third quarter of 2010.

BACT for NOx is Selective Non-Catalytic Reduction (ammonia injection currently used).

BACT for S02 is sorbent injection (limestone injection currently used). BACT for CO is thecirculating fluidized bed combustion process (currently used).

The current permitted emission limits and the actual emissions from the annual emission

inventory are presented below.

Actual Emissions

YEAR 2005 2006 Average Limit

NO (tons/year) 145.56 134.98 140.27 170.38

SO2(tons/year) 52.04 46.99 49.52 61.32

CO (tons/year) 83.78 80.74 82.26 460.34

PM10 (tons/year) 7.54 8.76 8.15 18.88

Note that the S02, annual emission average is within 40 tons per year of current limit. The NOx

annual emission average is within 25 tons per year of current limit. The VOC annual emission

average is within 25 tons per year of current limit. Likewise the PM1 0 annual emission average
Constituent NO (lbs/hi) SO2(lbs/br) CO (lbs/lw)

Limit 38.9 14.0 105.1

The emissions from the facility are not expected to change on an hourly basis.

It is Jasmin’s understanding that by being below the significant emissions increase thresholds for

a major modification, this request can be processed as a minor modification.

Please refer any questions you have regarding this request during your review to Dr. Ted Guth at

(619) 987-1111. Jasmin thanks you in advance for the expeditious review ofthis request, as wellas your continued support and guidance.

Sincerely,

/ _L- L i j

Bill Rossiter

Vice President

Title V Responsible Official

cc: Maggie Estrada, Constellation Energy

Ted Guth, Rio Bravo

Facility files
)

• SACTIs the moat stringent control technique (or the emissionS udi and clan of source. Cenifol techniques thet are no! achieved In practice

) or contained In se state Implenientatlon plsn must be coal ef!eclWe as wel( as (easibte, Econmio analysis to demonstrate cost offadllvaneas Is requited (or alt deterrnlnsllona that are not achieved Iii practice or contained In art EPA eppioved SIde tmplemeniaUon Plan. ‘This is a Summary Page for this Glass or 8ource Pennit Specific SACr Determinellons on Next Page(s)

Pollutant Achieved In Practice or ‘rechnoloutcally contained In the SIP Alternate Seeto Feasible £gulpnient 00

- 183 ppm, natural gsa nuxulary fuel

NOx 0.10 IbIMMBIu, ammonia

ItuldIzed circulating Injection and natwai gas bed oombustor W’NH3 awcliiary fuel injection PMI 0 0.045 lbIMMBtu, baghouse or ESP, and natural gas awdilary fuel

BOx 23 ppmv4 Lmestone Injootlon and natural gas andliaty1ueI

VOC 0,02 )b/MM9Iu 1natural gas awditaly fuel